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HomeCasesTodd E. Glass v. Foley & Lardner LLP
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Corpus matter record

Todd E. Glass v. Foley & Lardner LLP

W.D. Wisconsin · Nov 4, 2025 · Anita Marie Boor

WI / federalEditorial impact: lowpro sefake citationsmisrepresented authoritytortWarning
Direct answer

What happened in this matter?

The court issued a formal warning to a pro se litigant after discovering that his motion included multiple fabricated and misrepresented case citations, likely generated by AI. The court reminded the litigant of his duty under Rule 11 to verify all legal authority and cautioned that future reliance on non-existent citations could lead to sanctions.

Why the court cared
Fabricated: Case Law | Court could not verify the citation; the case 'S.G. v. SafeSport, 74 F.4th 864, 870 (7th Cir. 2023)' does not appear to exist. || Fabricated: Case Law | Court could not locate this district decision; 'Cafasso v. Central Refrigerated Servs., Inc., 486 F. Supp. 2d 1077, 1084 (W.D. Wis. 2007)' does not appear to exist in this district or under that reporter information. || Misrepresented: Case Law | Citation appears misrepresented: the cited case number 'Cressey v. Hamilton, No. 21-CV-2031 (D. Kan. 2021)' corresponds to a different matter in the District of Kansas.
Why it matters now
This record documents a Pro Se Litigant filing issue in W.D. Wisconsin, with the listed outcome: Warning.

Why this matter is tracked

In a legal malpractice action, the pro se plaintiff submitted motions containing multiple non-existent or misrepresented case citations. The court identified that the plaintiff relied on fabricated legal authority, likely generated by artificial intelligence. The court explicitly warned the plaintiff regarding the risks of using generative AI tools, noting their tendency to hallucinate citations and the resulting obligation under Federal Rule of Civil Procedure 11(b)(2) to ensure legal contentions are warranted by existing law. The court cautioned that future submissions of non-existent authority may result in sanctions. The court ultimately denied the plaintiff's broad discovery requests, granting only limited jurisdictional discovery to resolve a pending motion to dismiss.

Operational lesson

This record documents a Pro Se Litigant filing issue in W.D. Wisconsin, with the listed outcome: Warning.

Record details

WisconsinSingle-state evidence scope
Explore WIOpen its source-linked jurisdiction page and related matters.
CourtW.D. Wisconsin
Recorded decision-makerAnita Marie Boor · Magistrate Judge
Jurisdictionfederal
Circuit7th Circuit
DateNov 4, 2025
GE
AI toolGenerative artificial intelligence (unspecified)
Party typePro Se Litigant
OutcomeThe court issued a warning to the plaintiff regarding the use of AI-generated citations and granted limited jurisdictional discovery while denying the plaintiff's broader discovery requests.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court explicitly referenced the plaintiff's potential use of generative artificial intelligence tools.

Procedural posture

The court addressed a motion for jurisdictional discovery in a pending legal malpractice case, following a motion to dismiss for lack of diversity jurisdiction.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

3 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Court could not verify the citation; the case 'S.G. v. SafeSport, 74 F.4th 864, 870 (7th Cir. 2023)' does not appear to exist.
  2. Fabricated: Case Law | Court could not locate this district decision; 'Cafasso v. Central Refrigerated Servs., Inc., 486 F. Supp. 2d 1077, 1084 (W.D. Wis. 2007)' does not appear to exist in this district or under that reporter information.
  3. Misrepresented: Case Law | Citation appears misrepresented: the cited case number 'Cressey v. Hamilton, No. 21-CV-2031 (D. Kan. 2021)' corresponds to a different matter in the District of Kansas.

Questions this record answers

What happened in Todd E. Glass v. Foley & Lardner LLP?
The court issued a formal warning to a pro se litigant after discovering that his motion included multiple fabricated and misrepresented case citations, likely generated by AI. The court reminded the litigant of his duty under Rule 11 to verify all legal authority and cautioned that future reliance on non-existent citations could lead to sanctions.
Why does Todd E. Glass v. Foley & Lardner LLP matter for legal AI risk?
This record documents a Pro Se Litigant filing issue in W.D. Wisconsin, with the listed outcome: Warning.
What does the public record establish about Todd E. Glass v. Foley & Lardner LLP?
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Which source supports this Todd E. Glass v. Foley & Lardner LLP summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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